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Recommendation: To strengthen CBP's trade enforcement efforts, the Commissioner of CBP should direct the Office of Trade to include performance targets, when applicable, in addition to performance measures in its Priority Trade Issue strategic and annual plans.

Agency: Department of Homeland Security: United States Customs and Border ProtectionStatus: Open

Comments: As of September 2017, CBP indicated that CBP's Office of Trade has been performing biweekly reviews of current performance measure results and had scheduled a management planning meeting to closeout FY 2017. CBP indicated that these efforts will help establish the performance target baselines for FY 2018. CBP indicated that it plans to establish the FY 2018 priorities and Priority Trade Issue strategic and annual plans, but as of September 2017 has not provided timeframes for project completion.

Recommendation: To strengthen CBP's trade enforcement efforts, the Commissioner of CBP should direct the Office of Trade and the Office of Field Operations to develop a long-term hiring plan that articulates how CBP will reach its staffing targets for trade positions set in the Homeland Security Act and the agency's resource optimization model.

Agency: Department of Homeland Security: United States Customs and Border ProtectionStatus: Open

Comments: As of September 2017, CBP indicated that, in order to develop a long-term hiring plan, CBP's Office of Trade (OT), Office of Field Operations (OFO), and Human Resources Management (HRM) established a working group of key stakeholders to define the hiring challenges related to the trade positions. CBP identified the key stakeholders for the working group and was planning its first meeting for the working group. In the interim, CBP indicated that it was actively addressing trade hiring gaps through a variety of mechanisms that includes building recruiting partnerships with universities as well as closely tracking and monitoring the hiring of import specialists from initial announcement through entrance on duty.

Recommendation: To ensure that all relevant U.S. agencies have information on the effect of changes in U.S. policy related to Cuba, the Secretary of State, in consultation with the Department of Commerce, Department of the Treasury, U.S. Department of Agriculture, and other relevant agencies, should take steps to identify and begin to collect the information that would allow them to monitor changes in economic engagement, including with the Cuban private sector.

Agency: Department of StateStatus: Open

Comments: State concurred with this recommendation. In April 2017, State reported that it was taking steps to identify and collect information that would enable it to monitor the Cuban economy and changes in the economic environment, including with the Cuban private sector. For example, State noted that Embassy Havana had developed a plan for in-country travel and reporting by identifying key sectors and provinces that could provide additional insights on the Cuban economy. As of July 2017, State reported that the U.S. government had paused most bilateral engagement with the Cuban government while the incoming presidential administration conducted an interagency policy review. However, State noted that during this time the U.S. embassy in Havana produced several analytic cables discussing developments in the Cuban economy. With the release of the administration's National Security Presidential Memorandum "Strengthening the Policy of the United States Toward Cuba" in June 2017, State reported that it would work to implement this policy and would monitor developments in U.S. engagement with the private sector and Cuban economic trends. As of November 2017, State said that it was consulting with interagency partners on developments impacting the Cuban private sector and that it was working with other U.S. agencies to determine how to most effectively redirect resources away from the Cuban government and towards the private sector as called for in the administration's Cuba policy. However, State also noted that operations at Embassy Havana had been significantly affected by Hurricane Irma and the health attacks against U.S. diplomats in Cuba. According to State, the Secretary of State's September 2017 order for all non-emergency U.S. personnel to depart Cuba has limited the ability of Embassy Havana to report on developments there, but that the department will continue to monitor and report on Cuba's private sector to the greatest extent possible and as resources permit. GAO will continue to monitor State's efforts to implement this recommendation.

Recommendation: The Secretary of State should reconsider State's INKSNA process to ensure that it (1) complies with INKSNA's 6-month reporting cycle, and (2) minimizes delays in its ability to opt to impose sanctions.

Agency: Department of StateStatus: Open

Comments: In its written comments on the draft report, the Department of State concurred with our recommendation while expressing concerns about what it referred to as the inherent difficulties of producing 2006 Iran, North Korea, and Syria Nonproliferation Act (INKSNA) reports every six months as required by law. In a July 2016 letter, State noted that it had worked to minimize delays in its ability to impose sanctions pursuant to INKSNA reports and that it aims to eventually comply with INKSNA's six-month reporting cycle as it clears the existing backlog of INKSNA cases. Moreover, it noted that State had transmitted three INKSNA reports covering three years of activity (the latest covering calendar year 2013) within the last 18 months as evidence that it was making progress towards meeting the GAO recommendation. In 2017, State informed us that it was regularly reviewing lessons learned from previous reports and incorporating best practices into follow-on iterations of INKSNA reports. For example, it informed us, it had now streamlined the decision-making process to reduce the workload in making sanctions determinations by modifying the INKSNA decision and background memo to consolidate certain cases on which the interagency has achieved consensus recommendations, thereby simplifying the review and approval process. State reiterated its intention to eventually comply with INKSNA?s six-month reporting cycle as it clears the existing backlog. GAO will continue monitoring State's efforts to fully implement the recommendation.

Recommendation: To ensure that the performance measures used to evaluate the TAA for Firms program demonstrate program results and to help ensure that EDA can comprehensively evaluate the effectiveness of the program, the Secretary of Commerce should broaden the program's evaluation approach, for instance, by developing additional quantifiable outcome-oriented performance goals and measures for key program areas and conducting further analysis of the data to isolate the impact of the TAA for Firms program from other influences, such as economic trends.

Agency: Department of CommerceStatus: OpenPriority recommendation

Comments: Commerce concurred with our findings and recommendations. In December 2017, EDA provided additional information on its progress in implementing our recommendation. In 2012, EDA commissioned a study to inform the development of performance metrics and evaluation methods for the TAA for Firms program. Issued in October 2014, the study provided recommendations to EDA on potential performance metrics, tested the metrics by conducting a statistical analysis of TAA for Firms clients against a control group as well as a survey, and suggested data sources for conducting future evaluations of the TAA for Firms program. According to EDA officials, the study will help provide a foundation for more robust longitudinal performance measurement and enhanced policy analysis, thereby enabling EDA to more comprehensively evaluate the program. These officials noted that, in April 2017, the authors of the study finalized an operational toolkit containing recommended metrics and protocols for data collection and impact evaluation methods. In June 2017, EDA began to pilot test these recommended metrics and evaluation methods to improve program evaluation. In December 2017, EDA formed a working group to further refine the new evaluation system and metrics based on the results of the pilot tests. EDA expects to implement new evaluation system and metrics by the beginning of fiscal year 2019, according to EDA officials. We will continue to monitor Commerce's efforts to implement our recommendation.

Recommendation: To improve the data available to manage and evaluate the TAA for Firms program, the Secretary of Commerce should develop a data system to consistently collect, maintain, and analyze sufficiently reliable and up-to-date data on program operations and participant firms.

Agency: Department of CommerceStatus: OpenPriority recommendation

Comments: Commerce concurred with our findings and recommendations. In December 2017, EDA provided additional information on its progress in implementing our recommendation. According to EDA officials, as of December 2017, EDA had developed an improvement plan for its agency-wide data system for collecting data on program operations. According to these officials, EDA expects that the plan will guide EDA in transitioning to a new data system for the TAA for Firms program. We will continue to monitor Commerce's efforts to implement our recommendation.